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opportunity to participate in the partnership level proceeding.
Crowell v. Commissioner, 102 T.C. 683, 691 (1994).
Section 6223(a) generally provides that respondent shall
mail to each partner notice of the beginning of an administrative
proceeding at the partnership level with respect to a partnership
item, as well as notice of the final partnership administrative
adjustment (FPAA) resulting from any such proceeding. It is the
mailing of the FPAA that triggers the time period for a partner
to object to the partnership level adjustments by filing a
petition for readjustment. Sec. 6226(a). Failure by respondent
to provide notice of a partnership level proceeding to a partner
may result in that partner's share of the partnership items being
treated as nonpartnership items. Secs. 6223(e)(2),
6231(b)(1)(D). In light of petitioners' arguments, respondent
must be prepared to demonstrate compliance with the section
6223(a) notice requirements. Crowell v. Commissioner, supra at
691-692.
At trial, Josephine did not recall receiving an FPAA with
respect to the Barrister partnership proceeding. Catherine did
not testify as to whether or not she received one. However, the
validity of a properly mailed FPAA is not contingent upon actual
receipt by the partner of the FPAA. Id. at 692.
Respondent submitted certified records that show that FPAAs
for the Barrister partnership for 1983 and 1984 were mailed to
petitioners on September 5, 1989. We are convinced by evidence
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